Short answer. Generally no. Under Article 16 of the Labor Code, only public employment offices may engage in recruitment and placement of workers — private entities are barred unless they fall within the specific exceptions that the Code itself authorizes, such as licensed private recruitment agencies.
What the law says
no person or entity other than the public employment offices, shall engage in the recruitment and placement of workers
Labor Code, Article 16 — Recruitment Limited To Public Offices. Read the full provision →
The general rule: public offices handle recruitment
Article 16 of the Labor Code sets the default: recruitment and placement of workers is a function reserved to public employment offices. A private company — whether a corporation, partnership, or individual — cannot simply decide to recruit workers for others and collect fees for the service. The prohibition is broad: it covers any person or entity that is not a public employment office.
The exception that opens private recruitment
The same article carves out an exception: "Except as provided in Chapter II of this Title." Chapter II is precisely where the Labor Code authorizes private recruitment — but with conditions attached. Private entities that want to lawfully recruit and place workers must obtain the proper authority or license. Operating outside that authorization does not just expose a company to regulatory penalties; it can render the recruitment activity illegal, with serious consequences for those who carry it out.
Why this matters for workers
The restriction exists to protect workers from unscrupulous recruiters who collect placement fees, make false promises about jobs or wages, and then disappear. By channeling legitimate private recruitment through a licensed system, the law gives workers a traceable, accountable party. If a recruiter cannot produce proof of authorization, that is an immediate warning sign — not a technicality. Workers who have been recruited by an unauthorized entity should seek legal advice about their rights and remedies.
What the prohibition does not cover
Article 16 targets the business of recruiting and placing workers on behalf of others. It does not prevent a company from hiring its own employees directly — a business finding its own staff through its own processes is not engaging in "recruitment and placement" in the sense the article governs. The restriction is aimed at third-party intermediaries who recruit workers for other employers, particularly for a fee.
A note on article numbering
The Labor Code was administratively renumbered after its original enactment, so the same provision may appear under a different article number in some court decisions or references. Article 16 as published by the original text is the numbering used here. If you are reading a decision that cites the article under a different number, check whether it refers to the same provision before drawing conclusions.